Chapter 4 of the One Big Beautiful Bill (OBBBA) is titled “Investing In American Families, Communities.” Subchapter B of Chapter 4 is “Permanent investments in students and reforms to tax-exempt institutions.” That is where you will find “Modification of excise tax on investment income of certain private colleges and universities.” What is really amusing about this rewrite of IRC Section 4968 “Excise tax based on investment income of private colleges and universities” is that it applies to such a small number of institutions that you can identify them with a decent degree of certainty from publicly available information. The tax does not apply to state universities.

When Your Client’s World Is Bigger Than the U.S.
A lot of client meetings still start with the same assumptions: W-2 in a U.S. state, mortgage nearby, a 401(k), maybe some RSUs, and a college-savings plan. Yet many of those “simple” clients now own an apartment in another country, freelance for a foreign company, or have parents wiring money from overseas. The tax code does not see those details as background color; it treats them as organizing facts. This is where citizenship, residency, and domicile quietly step onto center stage. For planners, the challenge is not memorizing every cross-border rule. It is knowing when a client is no longer “just domestic” and shifting your planning framework before you stumble into penalties, double taxation, or blown opportunities.


